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510(k) Data Aggregation
(127 days)
AccuCTP Pro
AccuCTP Pro is an image processing software package to be used by trained professionals, including but not limited to physicians and medical technicians. The software runs on a standard off-the-shelf computer or a virtual platform, such as VMware, and can be used to perform image viewing, processing and analysis of brain images. Data and images are acquired through DICOM compliant imaging devices.
AccuCTP Pro provides both viewing and analysis capabilities for functional and dynamic imaging datasets acquired with CT Perfusion (CTP), which can visualize and analyze dynamic imaging data, showing properties of changes in contrast over time. This functionality includes calculation of parameters related to tissue flow (perfusion) and tissue blood volume.
AccuCTP Pro is an extension to legally cleared device AccuCTP (K220663).
AccuCTP Pro is a standalone software package that provides visualization and study of changes of tissue perfusion in digital images captured by CT (Computed Tomography). The software provides viewing, quantification, analysis and reporting capabilities, and it allows repeated use and continuous processing of data and can be deployed on a supportive customer's PC or a virtual platform that meets the minimum system requirements.
AccuCTP Pro works with the DICOM compliant medical image data. AccuCTP Pro provides tools for performing the following types of analysis:
- Volumetry of threshold maps
- Time intensity plots for dynamic time courses
- Measurement of mismatch between rCBF and Tmax threshold volumes obtained from the same scan.
The provided text describes the AccuCTP Pro device, which is an extension of a previously cleared device, AccuCTP. The submission is a "Special 510(k) Summary," indicating that it relies on substantial equivalence to a predicate device and focuses on minor changes.
Based on the provided information, the document does not contain details about a clinical study with acceptance criteria and a human reader performance study (MRMC) to prove the device meets specific performance metrics. Instead, it states that the algorithm and output settings of the AccuCTP Pro are the same as the predicate device (AccuCTP). Therefore, it relies on the previous predicate device's validation and general software verification and validation tests for the updated features.
Here's an analysis of the provided text with respect to your requested information:
1. A table of acceptance criteria and the reported device performance
The document does not provide a specific table of acceptance criteria for clinical performance and reported device performance metrics in the way one might expect for a new or significantly modified device requiring de novo validation. It primarily focuses on software verification and validation for the changes made.
The closest statement regarding "acceptance criteria" for performance is: "All tests met the pre-defined acceptance criteria and were passed." However, these refer to software verification tests, not clinical performance metrics.
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- Test Set: No specific sample size for a clinical test set is mentioned for AccuCTP Pro's validation. The document explicitly states: "No additional pre-clinical or clinical data is being provided with this submission." It defers to the predicate device's validation.
- Data Provenance: Not applicable as no new clinical data is presented.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience)
Not applicable, as no new clinical study data is presented requiring expert ground truth establishment for a test set.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable, as no new clinical study data is presented requiring adjudication.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No such MRMC study was performed or presented in this submission for AccuCTP Pro. The document focuses on software updates and relies on the predicate device's previous validation.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
This is implicitly addressed by the statement: "Phantom test and validation study were completed and reviewed as part of the predicate review (K220663), and the results concluded AccuCTP was safe and effective. As all algorithm and output of the subject device AccuCTP Pro is same as the predicate device AccuCTP, it can be concluded that AccuCTP Pro is acceptable for use." This suggests that the predicate device had a standalone evaluation, and since the algorithm hasn't changed, the standalone performance is assumed to be the same.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the predicate device's "phantom test and validation study," the ground truth would likely be established through physical phantom measurements or a gold standard comparison. The document does not specify the type of ground truth for the predicate.
8. The sample size for the training set
Not mentioned. The document describes the device as an "extension" with the "same fundamental scientific technology" and "same operation principle and algorithm embedded in the software" as the predicate. This suggests the training would have occurred for the original AccuCTP, and no new training data is discussed for AccuCTP Pro given that the algorithm is the same.
9. How the ground truth for the training set was established
Not mentioned, for the same reasons as in point 8.
Summary of what the document does provide regarding device acceptance and performance:
The acceptance of AccuCTP Pro is based on its substantial equivalence to the predicate device AccuCTP (K220663). The core argument is:
- The intended use, intended user, intended patient population, fundamental scientific technology, operation principle, and algorithm of AccuCTP Pro are the same as the predicate device.
- The changes in AccuCTP Pro are primarily related to data transmission mode, simplified manual operation, and updated software installation environments (e.g., compatibility with Linux and Windows, and virtual platforms like VMware, and basic PACS functions).
- These minor differences were evaluated through software verification and validation tests (import/export of DICOM, automatic selection/calculation, software management, case management, recalculation/adjustment, operating environment tests).
- Cybersecurity testing was performed according to FDA guidance.
- Human factors testing was conducted with fifteen qualified participants to validate usability and the user manual, concluding safe and effective use without residual use-related risks.
- The manufacturer relies on the original phantom test and validation study conducted for the predicate device (AccuCTP), arguing that since the algorithm and output are identical, the conclusions of safety and effectiveness for the predicate device extend to AccuCTP Pro.
In essence, AccuCTP Pro's "acceptance" is not demonstrated by new clinical performance data but by proving that its software updates do not introduce new questions of safety or effectiveness, due to the unchanged core algorithm and the successful completion of software engineering, cybersecurity, and usability tests.
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